Examples of how we can run pre-roll campaigns programmatically and offer a closed captioning solution:

Closed captioning is the visual display of the audio portion of video programming. Captioning provides access to individuals who are deaf or have hearing loss and is often used in places where it is difficult to hear a TV program, such as restaurants and exercise facilities. FCC rules require captioned programs shown on TV to be captioned when re-shown on the Internet.

We were stumped when a customer asked us how to serve pre-roll ads programmatically that include a closed captioning solution. YouTube was the obvious short term solution but had it’s limitations because we wanted to go off the platform and serve ads on other properties.

We really could not find a solution and looked to our serving partner LKQD to help us. The below examples are how we are running ads programmatically that include closed captioning

The pre-roll serves and starts playing with out the words on the screen

Throughout the duration of the pre-roll a small “CC” button appears in the right hand corner of the player ( as an overlay )

he user can simply click “CC” for the words to appear during the ad

Click it again and the words do not appear

See these examples below – screen grabs of the video player / ads in action:

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English Version

Spanish Version

Your customers need to provide the pre-roll file and enter a SRT file or a VTT file – these files are added to the ad sever and work in conjunction with the pre-roll. Contact www.lkqd.com if you are interested in this solution

We found out that the State of California requires closed captioning with any and all buys placed with state dollars – it’s a requirement that leads us to believe that most of these dollars are going to YouTube since they have the solution and this is an easy way to fulfill the requirement.

Interesting that there is not a lot of information out there about this requirement ( for the ads specifically ) by state or federally.

Federal law on video content ( after the pre-roll ) is clear and provided below for your reference:

Video programming rules

The Internet closed captioning rules only apply if the video programming was shown on TV in the U.S. with captions.
“Full-length video programming” is video programming that is shown on TV and is distributed to end users, substantially in its entirety, through the Internet.
“Video clips” are excerpts of full-length video programming that are posted online. The rules require video programming distributors that show programming on TV to post captioned clips of their programming on their own websites or applications (“apps”). At this time, the video clips rules do not apply to third party websites or apps.
Consumer-generated media (e.g., home videos) shown on the Internet are not required to be captioned, unless they were shown on TV with captions.
Movies shown on the Internet are not required to be captioned unless they have been previously shown on TV with captions.
Even if a program or a provider is exempt under the Commission’s rules, it may still have obligations under other federal laws to make its video programming accessible to individuals with disabilities.
Implementation schedule for captioning internet video programming

The following deadlines apply to video programming that is not in a distributor’s Internet online library before it is shown on TV with captions.

Full-length internet video programming

Full-length Internet video programming must be captioned if the programming is shown on TV in the U.S. with captions on or after the following dates:

September 30, 2012, for prerecorded programming that is not “edited for Internet distribution.” “Edited for Internet distribution” means the TV version has been substantially edited. Examples of substantial edits are deleting scenes or altering musical scores. Changing the number or duration of commercials is not considered substantial editing.
March 30, 2013, for live and near-live programming.
“Live programming” is defined as programming that is shown on TV substantially simultaneously with its performance.
“Near-live programming” is defined as programming that is performed and recorded less than 24 hours before it was first shown on TV.
September 30, 2013, for prerecorded programming that is substantially edited for Internet distribution.
Internet video clips

Internet video clips must be captioned if the associated programming is shown on TV in the U.S. with captions on or after the following dates:

January 1, 2016, where the video clip contains a single excerpt of a captioned TV program with the same video and audio that was shown on TV (“straight lift” clips).
January 1, 2017, where a single file contains multiple straight lift video clips (“montages”).
July 1, 2017, for video clips of live and near-live TV programming (such as news or sporting events).
For clips of live programming, up to a 12-hour delay is permitted in posting a captioned clip after the programming has been shown on TV.
For clips of near-live programming, up to an 8-hour delay is permitted in posting a captioned clip after the programming has been shown on TV.

Archival internet video programming

The following deadlines apply to video programming that a distributor already shows on the Internet. Distributors have extra time to add captions to video programming that they already show on the Internet and that is later shown on TV with captions, as follows:

Within 45 days after the date it is shown on TV with captions on or after March 30, 2014 and before March 30, 2015;
Within 30 days after the date it is shown on TV with captions on or after March 30, 2015 and before March 30, 2016; and
Within 15 days after the date it is shown on TV with captions on or after March 30, 2016.

Filing a complaint

If you experience a captioning problem after the implementation dates, you may file a written complaint with either the FCC or the video programming distributor or provider. If you choose to file your written complaint with the video programming distributor or provider, you may be able to find the contact information on the distributor’s or provider’s website. If you file your complaint with the FCC, the FCC will forward the complaint to the video programming distributor or provider.

Your written complaint must be filed within 60 days of the captioning problem. After receiving a complaint, either directly from you or from the FCC, the video programming distributor or provider will have 30 days to respond to the complaint. If you chose to first file your complaint with the video programming distributor or provider and it does not respond within 30 days, or if a dispute remains, you can still send your complaint to the FCC.